Epstein Secrets

om he coerced into performing sex acts "behind the walls of his opulent waterfront mansion," among other locations, "as often as three times a day." Julie K. Brown, How ajiiture Trump Cabinet member gave a serial sex abuser the deal of a *time, Miami Herald (Nov. 28, 2018), https://www.miamiherald.cominewsiloc

Media Company and investigative journalist Julie Brown, whose feature story about Epstein recently garne

onable, where a protective order is, as here, a blanket order entered by stipulation of the parties." In re NASDAQ Mkt.-Makers Antitrust Litig., 164 F.R.D. 346, 356 (S.D.N.Y. 1996). As for the last factor, the nature of the parties' reliance on the order does seem to weigh against modification. "The classi

EW YORK Plaintiff, - against - GHISLA1NE MAXWELL, Defendant. : Case No. 15-cv-7433 (RWS) MEMORANDUM OF LAW IN SUPPORT OF PROPOSED INTERVENORS JULIE BROWN AND MIAMI HERALD MEDIA COMPANY'S MOTION TO INTERVENE AND UNSEAL 1 EFTA00805407 Case 1:15-cv-07433-RWS Document 936 Filed 04/06/18 Page 2 of 21

OF LAW IN SUPPORT OF PROPOSED INTERVENORS JULIE BROWN AND MIAMI HERALD MEDIA COMPANY'S MOTION TO INTER

utyl Ether (MTBE) Prods. Liab. Litig., MDL No. 1358, 2013 WL 3531600 (S.D.N.Y. July 12, 2013) 10 In re NASDAQ Market-Makers Antitrust Litig., 164 F.R.D. 346 (S.D.N.Y. 1996) 7 ii EFTA00805409 Case 1:15-cv-07433-RWS Document 936 Filed 04/06/18 Page 4 of 21 In re Onusicom Grp., Inc. Sec. Litig., No. 0

om he coerced into performing sex acts "behind the walls of his opulent waterfront mansion," among other locations, "as often as three times a day." Julie K. Brown, How a future Trump Cabinet member gave a serial sex abuser the deal of a lifetime, Miami Herald (Nov. 28, 2018), https://www.miamiherald.com/news/

Media Company and investigative journalist Julie Brown, whose feature story about Epstein recently garne

onable, where a protective order is, as here, a blanket order entered by stipulation of the parties." In re NASDAQ Mkt.-Makers Antitrust Litig., 164 F.R.D. 346, 356 (S.D.N.Y. 1996). As for the last factor, the nature of the parties' reliance on the order does seem to weigh against modification. "The classi